Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee's alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.
Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee's alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.
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